Recent Projects

Coal combustion residuals, commonly known as coal ash, are the residual substances that remain after burning coal. They contain several chemicals that are toxic to human health, including arsenic, boron, lead, and mercury. The Environmental Protection Agency (EPA) proposed a rule that amends the regulatory framework for the disposal of coal ash. We submitted comments in January detailing how EPA fails to analyze the forgone benefits of the regulatory changes, which extend deadlines and eligibility for facilities that lack appropriate disposal capacity. We also submitted comments in April focusing on the second part of EPA's proposal, which fails to assess the forgone benefits of allowing facilities to seek approval for alternative basin liners. 

The federal Clean Car Standards promised steadily increasing fuel efficiency and lower vehicle emissions. The National Highway Traffic Safety Administration and the Environmental Protection Agency have now rolled back those standards, eviscerating important public health benefits and fuel savings for consumers. But the agencies’ own analysis shows that the rollback will cause more harm than good for society. And even the slight benefits that the agencies find under certain assumptions are premised on a flawed economic analysis that is riddled with problems.

We released a resource that explains the main economic problems with the rollback’s justification, identifying several critical errors and detailing how they invalidate the agencies' own claims

The Environmental Protection Agency’s (EPA) Federal Implementation Plan (FIP) for managing emissions on the Uintah and Ouray Indian Reservation in Utah proposes control requirements for new, modified, and existing oil and natural gas sources. Despite forecasting that the requirements would lead to a substantial decrease in methane emissions, EPA severely underestimates resulting benefits through the use of an “interim” social cost of methane metric that disregards the best peer-reviewed science. We submitted joint comments detailing EPA’s failure to adequately monetize and evaluate the benefits of the FIP.

The Environmental Protection Agency (EPA) proposed revisions to the National Primary Drinking Water Regulation for lead and copper. Our comments ask EPA to more fully monetize the benefits and better assess the significance of non-monetized benefits of the proposal. We also submitted a letter to EPA’s Science Advisory Board (SAB) summarizing our comments and encouraging the SAB to consider our points during its review of the proposed revisions.

The Federal Motor Carrier Safety Administration (FMCSA) proposed to extend the compliance dates of its entry-level commercial driver training program from 2020 to 2022. The program includes space and speed management training that reduces vehicle emissions. FMCSA projects that extending compliance dates would forgo hundreds of thousands of metric tons of greenhouse gas emissions. We submitted joint comments criticizing the agency’s regulatory impact analysis, which vastly underestimates forgone benefits and relies on flawed ‘interim values’ of the social cost of carbon.

Our resource compiles the greenhouse gas emissions and resulting damages from liquefied natural gas (LNG) export terminals.

The Department of Housing and Urban Development (HUD) has proposed to repeal and replace the 2015 Affirmatively Furthering Fair Housing rule, which sought to improve the process by which state and local governments that receive HUD funding identify and mitigate impediments to fair housing in their communities. We submitted comments detailing deficiencies in the Department’s regulatory impact analysis for the proposal. Specifically, we explain how HUD (1) ignores benefits of the 2015 rule that will be forgone under the proposed replacement, and (2) overestimates cost savings that will result from the proposed replacement.

The Department of Energy (DOE) proposed to change the way it selects energy efficiency standards by excluding certain efficiency levels as not "economically justified" on the grounds of effects to small businesses, market competition, or consumer convenience.The change, however, would allow DOE to irrationally and inconsistently give preference to whichever subset of economic impacts the agency wants to focus on in order to deem standards that otherwise achieve net benefits as instead being not economically justified. We submitted comments explaining how the proposal will not ensure consistent consideration of statutory factors.

The Council on Environmental Quality (CEQ) proposed changes to the regulations implementing the National Environmental Policy Act (NEPA), a decades-old statute that requires federal agencies to analyze the environmental impact of actions. We submitted comments explaining how the proposed rule runs afoul of the statute, drastically limiting agencies’ abilities to consider various effects and implement NEPA procedures. We also submitted joint comments detailing how the provisions would undermine analysis of climate effects, and encouraging CEQ to promote the use of the social cost of greenhouse gases.